GR 92803; (March, 1991) (Digest)
G.R. No. 92803; March 22, 1991
MALLI A. HATTA HATAIE (Deceased), Substituted by EDWIN O. HATTA, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM, respondents.
FACTS
Petitioner Malli A. Hatta Ha-taie served in various government positions from 1958 until his retirement as a Collector of Customs in 1988. Prior to his retirement, around 1985, he experienced blurring of vision, eye pain, and photophobia, which was diagnosed as neovascular glaucoma. Despite undergoing four unsuccessful eye operations, his vision deteriorated. Consequently, he filed a claim for disability benefits under the Employees’ Compensation Law (PD 626) with the GSIS.
The GSIS denied his claim, a decision affirmed by the Employees’ Compensation Commission (ECC). The ECC concluded that glaucoma is a disease characterized by increased intraocular pressure, with causes not definitively known but linked to non-work-related factors like advanced age and heredity. It found no proof that the risk of contracting neovascular glaucoma was increased by the petitioner’s occupation as Collector of Customs, nor was it an occupational disease listed under the law.
ISSUE
Whether the petitioner’s neovascular glaucoma is compensable under the Employees’ Compensation Law.
RULING
No, the ailment is not compensable. Under the governing law, PD 626, for a non-listed illness like neovascular glaucoma to be compensable, the claimant must prove that the risk of contracting the disease is increased by the working conditions. The Court found that the petitioner failed to discharge this burden of proof.
The petitioner argued that his work, which involved reading voluminous documents under strong light causing severe eye strain, led to his condition. The Court, however, explained that neovascular glaucoma is a secondary glaucoma caused by another underlying eye disease or injury. Mere eye strain from reading does not constitute a disease or an injury that can cause or contribute to the development of this specific ailment. Petitioner did not establish that his strain increased the risk of contracting neovascular glaucoma or any preceding ocular condition that could develop into it.
The Court also distinguished the cases cited by the petitioner. The old rulings on glaucoma under the repealed Workmen’s Compensation Act, which applied a presumption of compensability, are inapplicable. Other cited cases involved different factual scenarios, such as a direct traumatic injury to the eye or work-related cataract, where a clear causal link to employment was established. In contrast, no such relation between the petitioner’s customs work and his neovascular glaucoma was proven. Therefore, the denial of the claim was proper.